BIR Ruling No. 056-65

May 24, 1965 BIR RULING NO. 056-65 Mr. Horacio Montinola 750 Vito Cruz, Malate M a n i l a S i r : In reply to your letter dated January 9, 1965, I have the honor to inform you that an owner of a sugarland who offers the same for lease is not covered within the purview of a real estate dealer under Section 194(t) of the National Internal Revenue Code but within the purview of Section 3 of Commonwealth Act No. 567 as amended by Republic Act No. 1583, which provides as follows: "Section 3. When any land devoted to the cultivation of sugar cane is ceded to others by the owner or by the person in control thereof for a consideration, under a contract of lease or otherwise, such owner or the person in control thereof shall pay a tax equivalent to the difference between the money value of the rental or consideration collected and the amount representing twenty per centum of the assessed value of such land." LLphil Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue